The short answer
Under Ministerial Decision No. 244 of 2025, UAE businesses with revenue of AED 50 million or more must appoint an accredited e-invoicing provider by 31 July 2026 and go live on 1 January 2027. Businesses below AED 50 million appoint by 31 March 2027 and go live on 1 July 2027. Business-to-consumer sales are excluded for now.
What are the e-invoicing deadlines?
There are three mandatory phases, set by Ministerial Decision No. 244 of 2025:
| Who | Appoint provider by | Go live |
|---|---|---|
| Revenue AED 50 million or more | 31 July 2026 | 1 January 2027 |
| Revenue below AED 50 million | 31 March 2027 | 1 July 2027 |
| Government entities | 31 March 2027 | 1 October 2027 |
A pilot with a taxpayer working group and voluntary adoption both opened on 1 July 2026.
Which transactions are in scope?
Business-to-business and business-to-government transactions between persons conducting business in the UAE are in scope. Business-to-consumer transactions, and businesses that deal only with consumers, are excluded until the Minister sets a date (Ministerial Decision No. 244 of 2025). A PDF emailed to a customer is not an e-invoice under the system; invoices travel as structured data through accredited service providers.
“Business-to-Consumer Transactions shall not be subject to the Electronic Invoicing System”
What should a business do before its deadline?
Start eight to twelve months ahead. The work is mostly data, not software: clean customer master data with correct TRNs, map every invoice field your ERP produces to the mandatory fields, choose an accredited service provider, and test credit notes and corrections as well as standard invoices. Businesses below AED 50 million have until 31 March 2027 to appoint a provider, which leaves little time once year-end audits and corporate tax returns are done.
Are there penalties for missing the deadline?
Yes. Cabinet Decision No. 106 of 2025 sets administrative penalties for e-invoicing violations, including failing to appoint a provider or implement the system on time. Businesses that adopt voluntarily before their phase are not penalised under that decision until they become mandatory participants. Penalty amounts can change by decision, so check the current schedule before you rely on a figure.
Frequently asked questions
Does e-invoicing apply to free zone companies?
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Yes, for in-scope business-to-business and business-to-government transactions, unless a specific exclusion applies.
Which revenue figure decides my phase?
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The decision uses annual revenue; confirm the measurement period with your adviser, especially if you are near AED 50 million.
Can I keep sending PDF invoices?
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Not for in-scope transactions once your phase starts. Structured e-invoices exchanged through an accredited provider replace them.
Sources
- Ministerial Decision No. 244 of 2025 on the Implementation of the Electronic Invoicing System — UAE Ministry of Finance. Checked 16 October 2026.
- Registration for VAT (mandatory and voluntary thresholds) — Federal Tax Authority. Checked 16 October 2026.